Joseph M. Grey Public Accountant, P.C. - Page 2




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               Joseph M. Grey (an officer), for petitioner.                           
               Linda P. Azmon, for respondent.                                        

                                       OPINION                                        
               HALPERN, Judge:  This is an action for redetermination of              
          employment status.  On February 23, 2000, respondent mailed to              
          petitioner a Notice of Determination Concerning Worker                      
          Classification under Section 7436 (the notice).  By the notice,             
          respondent informed petitioner that he had determined that                  
          Joseph M. Grey is classified as an employee of petitioner’s for             
          purposes of the Federal employment taxes imposed by subtitle C of           
          the Internal Revenue Code and that petitioner is not entitled to            
          relief from that classification under section 530 of the Revenue            
          Act of 1978, Pub. L. 95-600, 92 Stat. 2885, as amended (section             
          530).  Attached to the notice is a schedule (the schedule)                  
          setting forth petitioner’s liabilities for (1) Federal Insurance            
          Contribution Act (FICA) taxes and (2) Federal Unemployment Tax              
          Act (FUTA) taxes, as follows:                                               
                    Tax       Quarter or Year          Amount                         
                    FICA           1/1995              $1,430                         
                    FICA           2/1995              1,430                          
                    FICA           3/1995              1,430                          
                    FICA           4/1995              1,430                          
                    FICA           1/1996              1,448                          
                    FICA           2/1996              1,448                          
                    FICA           3/1996              1,448                          
                    FICA           4/1996              1,448                          
                    FUTA           1995                434                            
                    FUTA           1996                434                            







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